Montana’s healthy and diverse natural environment, one which we know, love and
unfortunately and occasionally some take for granted, has been predetermined by its climate. Due to the state’s size, location, geographic features and elevation, Montana’s climate is variable and,
in some cases, extreme. Our indigenous flora and fauna can be sensitive to even the most subtle, not to mention the most dramatic climate changes, a climate by the way which is changing before our
eyes. In the Introduction of the State of Montana’s draft Montana Climate Solution Plan, on page 3, it states the following:

“Our temperatures are 3 degrees warmer on average than
they were just a few decades ago…”

Some may refuse to recognize the science. Some may refuse to recognize the
reality on the ground, but that doesn’t alter what is true. Our climate is changing. It is getting warmer and drier. Further on in MCSP’s Introduction, there is this proclamation.

“According to the Montana Climate Assessment (MCA), the
State could experience an additional 3-7 degrees increase in average temperatures by mid-century, including an increase in incidences of extreme heat that could dramatically increase many of these
impacts moving forward.”

As a result, we can only imagine what kind of changes those will have on our
wildlife. We can already see evidence of some of those changes today. We see it in their population numbers, in their behavior, and in the loss of their habitat. A variety of species such as pika,
wolverines, grizzly bears, and moose, etc. are just some of the species whereby science has documented climate causal effects. The same could be said for the health of our forests and our biome.
Again, as goes the health of our forests, so goes the health of our wildlife as our forests provide food, water, security and protection. It is truly a delicate and intricate balance of
nature.

It is in this context that Gallatin Wildlife Association (GWA) would like to
comment on Montana Climate Solutions Plan (MCSP), a document issued by the Montana Climate Solution Council (MCSC) a product of Governor Bullock’s Executive Order 8-2019. GWA is a non-profit, all
volunteer, wildlife conservation organization representing hunters, anglers and other wildlife advocates in Southwest Montana and elsewhere. Our mission is to protect habitat and conserve fish and
wildlife. GWA supports sustainable management of fish and wildlife populations through fair chase public hunting and fishing opportunities that will ensure these traditions are passed on for future
generations to enjoy.

Preparing Montanans for Climate Impacts:

The MCSC has listed eight (8) preliminary recommendations in which it says
“will prepare our communities, infrastructure and economies for anticipated climate impacts.” No matter what is recommended, we must realize that actions and decisions
should be based upon science and common sense. We must open ourselves up to ideas and policies that may be contrary to traditional thought. In the 21st century, we must realize and
acknowledge that perhaps this new century deserves a different perspective; that the old way of doing things aren’t applicable anymore.

Items F, G, and H are three of the eight recommendations which reference forest
management, forest resiliency, wildlife and watershed quality. These three recommendations will be discussed below inconsiderable detail.

1F. BUILD THE
RESILIENCE OF MONTANA’S PRIVATE WORKING LANDSCAPES (FARMS, RANGELANDS, AND FORESTS) AND SUPPORT VOLUNTARY AND INCENTIVE-DRIVEN EFFORTS FOR CLIMATE SMART MANAGEMENT THAT REDUCES RISKS, IMPROVES BOTTOM
LINES, AND ENHANCES CARBON STORAGE IN SOILS, FORESTS AND WOOD PRODUCTS.

Agriculture:

There needs to be an honest look at how the role agriculture is accentuating
climate change. The management of our private landscapes (whether they are farms, ranches or forests) have a significant role in our changing climate; just as much as the management of our tribal,
state or federal lands. It is not just government’s role or responsibility to fight climate change; it is all of ours. We all must understand the consequences of our own actions and take
responsibility for it.

In an article in The Hill1, a website based in Washington
D.C., dated August 3, 2019, Erik Molvar, a wildlife biologist and Executive Director for Western Watersheds Project states the facts as listed below. They are specific and are not covered in MCSC’s
recommendations, but they should be acknowledged. Even though factoid #1 has and will receive ridicule, that doesn’t mean we shouldn’t address it. We are going to have to ask ourselves a question.
Are we serious in addressing the issue of carbon in our atmosphere or not? Agriculture should not be immune from debate. Another question is: What do we do about it?

1.“Livestock belching, farting and manure emissions of this and other gases has been estimated to account for 14 to 18 percent of the total human-induced greenhouse gases that are responsible for climate change. The remaining 82 to 86 percent of carbon emissions into the atmosphere comes from taking
carbon out of the ground and pumping it into the atmosphere, whether through equally-potent methane leaks from natural gas wellfields and pipelines or through burning fuels to produce carbon
dioxide.”

2.“But the livestock also convert and degrade lands, radically reducing carbon sequestration — the natural ability of the biosphere to soak up atmospheric
carbon — creating an even greater climate problem than methane emissions themselves.”

3.“Less visibly but perhaps more importantly, livestock grazing on the world’s grasslands, shrub steppes and deserts can
cause even greater
withdrawals from a carbon banking standpoint than cutting down the forests. Livestock grazing eliminates
deep-rooted native grasses and wildflowers, replacing them with shallow-rooted annual weeds that thrive in disturbed environments and die every year, releasing their carbon back to the atmosphere.
Annual weeds therefore have little ability to store carbon in the soil.”

4.“In addition, once rangelands become degraded through overgrazing, shrubs sometimes increase, but clearing these shrubs to stimulate forage production
for livestock further
cripples the land’s ability to store carbon.”

To be fair, a few
key strategy points addressing some of these issues are contained in the draft MCSP. They are listed here.

“Recognize Montana producers for their high adoption rates of soil health practices including no/conservation tillage and cover
crops, improved grazing systems and efforts to maintain and restore native rangelands.”

“Explore partnerships with producers and
their associations to research conservation practice adoption factors, cost savings, and climate related co-benefits, such as carbon storage, increased water holding capacity in soils, and reductions
in pest and disease risks.”

The emphasis here is
on increasing soil moisture and holding on to that capacity, restore native rangelands, and carbon storage. But the points made by Mr. Erick Molvar explain why this might be more difficult than it
looks. If the agricultural industry doesn’t acknowledge or understand that some of the current practices are the problem, how will we see improvements? That is the enigma. In other words, how can we
make improvements in our managing practices, if we refuse to acknowledge the fact that how we are managing our rangelands is the opposite of what is needed. Hopefully education will be part of this
plan.

Farmers and ranchers
cannot continue to overgraze or overuse pastures or rangelands and expect improvements in range conditions. As Mr. Molvar reported, livestock grazing uproots the native grasses and wild flowers, and
allows exotic species of weeds to replace them. One of the most common of these invasive species is cheatgrass (Bromus tectorum). This has been devastating on public rangelands throughout the west,
but the solution on public land should be the same as that on private lands. GWA would like to reference a summary from a scientific research article in the Journal of Applied Ecology written
and published by Reisner, Michael D., et al,2 entitled Conditions favouring Bromus tectorum dominance of endangered sagebrush steppe ecosystems. Note the BSC cover that is
mentioned in the first bullet point is referring to biological soil crusts.

“Model results imply that bunchgrass community structure, abundance and composition, along
with BSC cover, play important roles in controlling B. tectorum dominance.”

If the goal is to conserve and restore resistance of these systems, managers should
consider maintaining or restoring: (i) high bunchgrass cover and structure characterized by spatially dispersed bunchgrasses and small gaps between them; (ii) a diverse assemblage of bunchgrass
species to maximize competitive interactions with B. tectorum in time and space; and (iii) biological soil crusts to limit B. tectorum establishment. Passive restoration by reducing cumulative cattle
grazing may be one of the most effective means of achieving these three goals.

The science is out
there and we can provide more upon request. The key point is there are ways and methods we can improve rangeland conditions, conditions which will achieve the desired results, but the question is do
we have the will? Will the state inform and encourage private land holders to do what is required? Further, in the listing of key strategies, there is the suggestion of implementing financial rewards
or incentives for those willing to make changes in management practices. We applaud the MCSC for this effort and commitment.

As for forests in
private hands, the management of those forests should not be much different than those forests on state, tribal or federal lands. Private landowners must also be made aware of the additional science,
the new science if you will. The understanding of private landowners that trees are a source of carbon sequestration. This is crucial to our implementation of a better land-use management policy.
Much like those comments pertaining to agriculture, comments regarding the management of our Nations forests (whether it be private or public) should be applied to both.

Soils:

The importance of
improving soil’s ability to aid in the sequestration of carbon shouldn’t be undervalued. In an article by Renee Cho3, dated February 21, 2018, on a blogsite called State of the Planet
hosted by Earth Institute and Columbia University, Renee lays out several premises proving the soils ability to help in fighting climate change.

“Sequestering carbon in soil, however, is a relatively natural
way of removing carbon dioxide from the atmosphere with fewer impacts on land and water, less need for energy, and lower costs.”

“The Earth’s soils contain about
2,500 gigatons of carbon—that’s more than three times the amount of carbon in the atmosphere and four times the amount stored in all living plants and animals.”

“How much carbon soils can absorb and how long they
can store it varies by location and is effectively determined by how the land is managed. Because almost half the land that can support plant life on Earth has been converted to croplands, pastures
and rangelands, soils have actually lost 50 to 70 percent of the carbon they once held. This has contributed about a quarter of all the manmade global greenhouse gas emissions that are warming the
planet.”

“Agricultural practices that disturb the soil—such as
tilling, planting mono-crops, removing crop residue, excessive use of fertilizers and pesticides and over-grazing—expose the carbon in the soil to oxygen, allowing it to burn off into the atmosphere.
Deforestation, thawing
permafrost, and the draining of peatlands also cause soils to release carbon.”

“A 2017 study estimated that
with better management, global croplands have the potential to store an additional 1.85 gigatons carbon each year—as much as the global transportation sector emits annually. Moreover, some scientists
believe soils could continue to sequester carbon for 20 to 40 years before they become saturated.”

This impact of
soil’s ability to sequester carbon cannot be understated, but this highlights the impact that man has had on our natural environment. If mankind would actually take the time and money to try restore
the natural balance back to our soils, water, and forests; just imagine the impact we could have in fighting climate change. But it takes willingness, the commitment, and the dollars to do so. GWA
hopes that these comments will provide the impetus and incentive to act upon what these recommendations. There is scientific proof these acts will help.

1G. SUPPORT CLIMATE
RESILIENT FORESTS, RANGELANDS, AND WILDLIFE USING AN ALL-LANDS, ALL-HANDS APPROACH ACROSS OWNERSHIP BOUNDARIES.

The first two key strategies listed in the MCSP under 1G are listed here and
they raise questions. First the text.

What is the definition of “active forest-management” as referenced in the first
key strategy? We don’t see definition of the term and traditionally speaking this has referred to active engagement by man to log, thin or selective cut forests. In some cases, reference has even
been made to chemically treat areas to control vegetative growth. GWA feels these manmade solutions are not applicable on public lands, solutions which we feel don’t belong in a natural
system.

In an article entitled “Logging drives carbon emissions from U.S. forests,
escalates climate crisis” by Smith, Danna, et al4, dated Oct. 2, 2019 in the Missoula Current, there is this statement.

1.“Many people are
aware of the importance of protecting rainforests in Brazil to help mitigate climate change, but few realize that more logging occurs in the US, and more wood is consumed here,
than in any other nation globally. The rate and scale of logging in the Southeastern US alone is four times that in South American rainforests.”

2.“But the
promotion of logging to supposedly curb carbon emissions is just part of the Administration’s ongoing alignment with industry and troubling pattern of climate science denial. Carbon emissions from
logging in the U.S. are 10 times
higher than the combined emissions from wildland fire and tree mortality from native bark
beetles.”

“Fire only consumes a
minor percentage of forest carbon, while improving availability of key nutrients and stimulating rapid forest regeneration. Within a decade after fire, more
carbon has been pulled out of the atmosphere than was emitted.”

“When trees die from
drought and native bark beetles, no carbon is consumed or emitted initially, and carbon emissions from decay are extremely small, and slow, while decaying wood helps keeps soils productive, which
enhances carbon sequestration capacity over time.”

This article highlights the science of carbon sequestration and the role that
forests play in that effort. The practices supported by the science can be applied onto all private, tribal, state and federal lands. These thoughts should place a whole new insight in how we view
the role of our forests and value of protecting them.

1.“Using Random Forest ensemble machine learning, we
found daily fire weather was the most important predictor of fire severity, followed by stand age and ownership, followed by topographic features. Estimates of pre-fire forest biomass were not an
important predictor of fire severity.”

In other words, day to day weather (such as hot, dry and those during periods
of drought) and those highly-managed forests are more susceptible to severe fires than those that aren’t managed to that degree. Forests with high biomass are not driving factors of wildfire
severity. In summary of the article it states the following principals, principals which proves the point that forest management may not be the solution we once thought it was.

3.“First, it brings into question the conventional view that fire exclusion
in older forests is the dominant driver of fire severity across landscapes.”

5.“However, in the landscape we studied, intensive plantation forestry
appears to have a greater impact on fire severity than decades of fire exclusion.”

6.“Second, higher fire severity in plantations potentially flips the
perceived risk and hazard in multi-owner landscapes, because higher severity fire on intensively managed private lands implies they are the greater source of risk than older forests on federal
lands.”

7.“These older forests likely now experience higher fire severity than
historically due to decades of fire exclusion, yet in comparison to intensively managed plantations, the effects of decades of fire exclusion in older forests appear to be less important than
increased severity in young intensively managed plantations on private industrial lands.”

Wildlife:

Of the key strategies mentioned, three of them recommend efforts to honestly
assess wildlife and wildlife habitat, to assess climate adaption needs on a variety of species, and to communicate those assessments and needs to the public and users. The key here of course is the
word “honestly”. For years, GWA has been trying to promote the dangers of climate change on a variety of species, some of those listed above in the introduction. As a result, we applaud MCSC for
acknowledging and recommending these proposed actions. But we are skeptical, and the reason for that skepticism has been the actions of previous and recent state and federal land-use and wildlife
management agencies. So many times, it seems as if state and federal agencies are at odds with each other or even at odds within their own government. How will this message be conveyed to all actors
and what assurances are there that agencies would change direction as recommended?

A few key strategies mentioned within the context of wildlife is the idea of
strengthening partnerships between private, local, state, tribal and federal entities. In addition to partnerships, the MCSC also recommends the building of new collaborations. GWA has also
been somewhat skeptical of collaborations because based upon prior experience and beliefs, the use of collaborations has meant an excuse of likeminded user groups to form a coalition drowning out
opposing views. There is also a belief that government agencies use collaboration as a mechanism for job avoidance, as a way for them to avoid making the hard decisions. GWA is not and would not be
in favor of such participation if this were to be the case. Any collaboration must include all voices who want to participate. Normally we would applaud the partnering of government agencies coming
together to make positive changes on the behalf of wildlife. But again, the skepticism comes into play because we have seen massive political interference by ideological players manipulating the
system to carry out policies undermining the goal. Besides, there are some principals that maybe, just maybe should not be compromised away.

Again, we applaud such methods and actions. But we also recognize that several
state and federal agencies seemed to have gone out of their way to weaken those protections, not strengthen them. Even the Department of Environmental Quality (DEQ) has made decisions that are
counter to these goals. When we say an honest assessment, we mean a complete honest assessment and we suggest that the public and NGOs be allowed to have a voice in this effort.

“Warmer temperatures and
decreasing snowpack in the region favor survival of white‐tailed deer. In contrast, moose may become physiologically stressed in
response to warming, and increasing deer populations spreading disease will exacerbate the problem.”

“Although there is
some uncertainty about exactly how the climate will change, and to what degree, robust projections suggest that deer populations will increase in response to climate change and moose populations will
decrease.”

This is just an example of the science available and why reference should be
made to it by state and local officials. The public must come to understand the replications of climate change. Right now, we believe they are not. This kind of data can be and has been replicated
elsewhere and one that GWA has been trying to bring forth to the public through letters and comments specifically ie: the U.S. Forest Service. It is one that the state of Montana needs to be aware.
Montana Fish, Wildlife and Parks cannot ignore the reality and we hope that the MCSP can be instilled into other state agencies.

1H: PROTECTING MONTANA’S WATER QUALITY AND QUANTITY FROM CLIMATE
CHANGE.

There are only 4 key strategies listed under recommendation 1H and they are
simple enough to be listed here.

“Promote wetland and stream function through restoring and
protecting river corridors, floodplains and wetlands and supporting related education efforts.”

“Integrate local drought and water quality planning into other
climate and land use planning efforts.”

“Invest in tools to improve statewide monitoring and assessment
of water resources.”

“Incorporate green infrastructure and
adaptive water management that combine flooding mitigation, water storage, and water quality improvement into stormwater infrastructure and natural storage utilizing ditches, floodplains, and
irrigated lands.”

As GWA comments and reads these recommendations, it is not hard to understand
where we as a people and a state have gone wrong when it comes to the protection of our water resources. This proves our point all along; we as a people know what to do, we just don’t do it, or in
some cases, we don’t want to do it. The politics gets in the way. These 4 recommendations are actions that we as a Nation and a state should have been doing all along. If this document changes the
existing paradigm, our existing attitude, then so much the better. But our fear is that this will become lip service. We urge DEQ and the state to prove us wrong.

Watersheds:

The first place when discussing best ways to protect Montana’s water supply is
to protect the state’s watersheds. This would enhance both water quality and quantity. And in that regard, it should be stated that the majority of the state’s headwaters lie on federal lands, either
Bureau of Land Management, National Forests or National Parks. As a result, it is imperative there should be state input as well as public input with federal officials on the best methodology, on the
need and the desire to make sure our watersheds are being properly protected from ongoing degradation. We should know, one of the primary functions of our National Forest Land was to protect the
Nation’s watersheds. It has been so since the establishment of the Forest Reserve Act of 1891. But slowly over time, through multiple use, and other legislation, our watersheds have almost come to be
expendable. Our opinion.

The working group found that
watershed degradation has impacted the cost of water treatment for about 1 in 3 large cities, increasing the costs by about half. Added up globally, the team calculated the cost to be a staggering
$5.4 billion per year.

This is a remarkable and alarming statistic. Even though this is based upon
global trends, it does represent the seriousness of how mankind has not done what is needed to protect our watersheds. If climate change were not an exacerbating factor in our watershed degradation,
our watersheds would still need national attention. But it is, therefore making our degradation even more dire. To place this concern in more practical and realistic terms, we urge DEQ to acknowledge
these summations from a journal article entitled “Water quality degradation effects on freshwater availability: Impacts to human
activities”by Peters8, N.E., Meybeck, Michel. From their abstract, there are these
points.

“Human activities on all spatial
scales affect both water quality and quantity. Alteration of the landscape and associated vegetation has not only changed the water balance, but typically has altered processes that control water
quality. Effects of human activities on a small scale are relevant to an entire drainage basin. Furthermore, local, regional, and global differences in climate and water flow are considerable,
causing varying effects of human activities on land and water quality and quantity, depending on location within a watershed, geology, biology, physiographic characteristics, and
climate.”

“These natural
characteristics also greatly control human activities, which will, in turn, modify (or affect) the natural composition of water. One of the most important issues for effective resource management is
recognition of cyclical and cascading effects of human activities on the water quality and quantity along hydrologic pathways.”

“The degradation of
water quality in one part of a watershed can have negative effects on users downstream. Everyone lives downstream of the effects of some human activity. An extremely important factor is that
substances added to the atmosphere, land, and water generally have relatively long-time scales for removal or clean up.”

“Policy alone will not
solve many of the degradation issues, but a combination of policy, education, scientific knowledge, planning, and enforcement of applicable laws can provide mechanisms for slowing the rate of
degradation and provide human and environmental protection. Such an integrated approach is needed to effectively manage land and water resources.”

In short, human activity affects water quality. The more disturbances occurring
on private, local, state, tribal and federal natural lands, the more it will affect the quality and even the quantity of our Nation and state’s water. The types of disturbances are varied and
multiple, all the way from agricultural impacts to recreation to soil productivity and fires.

We urge the MCSC to review and implement elements of the Forest Service paper
FS-977 dated May 2011 entitled Watershed Condition Framework: A Framework for Assessing and Tracking Changes to Watershed Condition9. The purpose of this paper was to
assess and monitor watersheds on Forest Service lands across the Nation and to adopt restoration for those watersheds that need improvement in the face of climate change.

Wilderness:

In actuality, GWA believes that one of the best protections of our watersheds
is the application of wilderness, where and when appropriate. Wilderness areas eliminate the destructive effects of roadways, mechanized and motorized uses, protects water quality and quantity by
preserving the integrity along riparian areas, plays and active role in carbon sequestration, protects the biological diversity of plants and animals, and to some degree may limit grazing. All of
these positive aspects of wilderness also cut down on the likelihood of erosion, soil compaction and loss of soil integrity.

Agriculture:

On a side note, an issue that is exacerbated by climate change is the affect
agriculture is having on our Nation’s rivers. The following facts indicate that perhaps agriculture is having a larger impact on the quality and quantity of our Nation’s water than politicians and
the agriculture community realizes. GWA would like to refer DEQ to a National Geographic article by Alejandra Borunda10 dated March 2, 2020. She bases her article upon the research
done by Brian Richter, the lead author of the study. In that article entitled “How beef eaters in cities are draining rivers in the West”, there are these critical points.

1.“The biggest user of river water by far, though, is agriculture and new
research shows that across the western United States, a third of all consumed water goes to irrigate crops not for human consumption, but that are used to feed beef and dairy cattle. In the Colorado
River basin, its over 50 percent.”

2.“They tracked the water taken out of rivers and streams in each little fraction of a watershed to the places it was being used to irrigate crops, and in many cases could trace its
journey to farms or counties that grew certain cattle feed crops…..They could also estimate how much the water withdrawals from individual watersheds would endanger fish populations living in those
delicate waters. Low summer water flows in rivers across the region, particularly when caused by water extractions that end up irrigating cattle feed crops, have added to the local extinction risk
faced by nearly 700 species of fish.”

3.“Beef cattle and dairy industries expanded across the western U.S. over subsequent decades, but the animals needed more feed than they could forage from the dry landscapes—so feed
crops like alfalfa became more and more critical to the burgeoning herds. As large-scale irrigation projects bloomed across the west, more and more cattle-feed crops could be grown, supporting
ever-expanding herds. Some 23 million acres of alfalfa are grown across the U.S.”

4.Just last week, a team published a paper in Science showing that the
Colorado’s flow is projected to diminish another 20 to 30 percent by the middle of the century……Richter and his colleagues did the math and figured out that if 20 percent of the cropland currently
used for cattle feed in the upper part of the Colorado River basin were to lie fallow, the states involved could meet their water use goals.

We present these facts here to show that agriculture is a dominant user of
water, in our Nation, in Montana and elsewhere. The water cycle, agriculture and climate change are all interrelated. One of the suggestions that the author above mentions (not highlighted here) is
to pay farmers not to farm. That’s the dire situation. The lack of mention and inclusion over the role that agriculture would play in trying to achieve the goal of protecting Montana’s water quantity
and quality is doomed for failure. This role must be addressed.

“Beaver trapping was the first large-scale Euro-American
alteration of watersheds.”

But the issues we wanted to stress can best summed up by the article by Ben
Goldfarb13 in SierraMagazine dated July 3, 2018 entitled “Beavers are the Ultimate Ecosystem Engeneers.” According to Goldbarb, beavers can:

1.Filtering pollution. He states: “Every year, America’s farmers use
20 million tons of synthetic fertilizers. When those chemicals reach the sea, they breed low-oxygen “dead Zones” devoid of marine life”. In Rhode Island, researchers discovered that beavers could cut
agricultural pollution by up to 45 percent, keeping estuaries healthy.

2.“Storing groundwater. The weight of beaver ponds forces water into the
ground, recharging the aquifers that we’re depleting at a breakneck pace. Some researchers estimate that ponds up to 10 times as much water belowground as above it.”

3.“Wetlands are cradles of life: In some arid regions, they support 80
percent of the species despite covering just 2 percent of the landscape.”

4.“Preventing Floods: Although most people associate beavers with flooding,
their ponds can actually help prevent catastrophic deluges by slowing, spreading, and storing water.”

5.“Adapting to climate change: As the climate warms, more precipitation falls
as rain instead of snow, running off directly to the ocean rather than gradually melting throughout the summer……combine snow decline by relocating beavers to headwaters on public lands, where their
ponds capture rainfall and keep streams full as the planet gets hotter.”

“Storing carbon:Just as forests suck carbon
from the atmosphere and sequester it in wood, so beavers trap carbon in the form of organic sediment that settles to the bottom of their ponds.”

These facets of beaver activity are a plus during hotter and drier summers.
Beavers support groundwater percolation, prevents surface-water runoff, and maintains biodiversity and biological integrity. Once again man’s arrogance of not understanding the delicate balancing
role of nature nearly wiped out this beneficial species. But beaver is making a comeback and as we are finding out, there is more of a need, more than ever to restore the balance and also aid in the
help to fight climate change impacts.

In Conclusion:

GWA has tried to confine our comments to issues that either directly or
indirectly relate to wildlife, wildlands, and watersheds, each of which are prescribed in the MCSP. We tried to make the point, all of these issues are concentric to each other, but ever more so as
the health of each are dependent upon our changing climate. To deny climate change doesn’t exist or that specific individuals or groups have no role to play in combating it is selfish and
shortsighted. As we said, just because some politicians, groups or organizations don’t believe in climate change doesn’t make it any less true. We all have a role to play. We feel GWA’s role is to be
the voice for the voiceless, recognizing that wildlife are the ones most likely to pay the highest price for man’s actions, the price of extinction.

“That human actions threaten more species with global
extinction now than ever before. An average of around 25 percent of species in assessed animal and plant groups are threatened suggesting that around 1 million species already face extinction, many
within decades, unless action is taken to reduce the intensity of drivers of biodiversity loss. Without such action, there will be a further acceleration in the global rate of species extinction,
which is already at least tens to hundreds of times higher than it was averaged over the past 10 million years.

Globally, local varieties and breeds of domesticated
plants and animals are disappearing. This loss of diversity, including genetic diversity, poses a serious risk to global food security by undermining the resilience of many agricultural systems to
threats such as pests, pathogens and climate change.”

This is why GWA felt the need to comment. Our changing climate is affecting our
biodiversity, the world as we know it. The gift of inhabiting this world with the untold variety of species on this planet is what makes life worth living. Far too long, man has either ignored, or
taken advantage of the life around us with an arrogance that is shameful. The same holds true for the variety of life here in Montana. We are blessed with so many wildlands which still holds
potential for its wildlife, to squander that or let the world slowly change around us without trying to protect all living things is simply unthinkable.

So many of our species are very sensitive to these ongoing changes in our
climate. As we said in our introduction, whether it be pika, wolverines, grizzly bears, or moose; large or small; or even the many species of fish in our waters, there needs to be a governing body
that is trying to establish criteria and/or policy to minimize or at least mitigate the ongoing crisis that is here.

GWA applauds the intent behind this effort. We tried to comment in a
constructive way in order to make this document even more effective. We could provide more research, more scientific papers and journals to prove our point, but we hope our leads will direct you to
do the same, in the proper direction. Please accept our comments in the sincerity in which they were given.

R. I. McDonald,
K. F. Weber, J. Padowski, T. Boucher, & D. Shemie. “Proceedings of the National Academy of Sciences of the United States of America”, July 25, 2016, PNAS Early Edition, DOI:
10.1073/pnas.1605354113

13. Diaz, Sandra, et al,“Summary for policymakers of the global assessment report on
biodiversity and ecosystem services of the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services.”,Intergovernmental Science-Policy Platform on Biodiversity and
Ecosystem Services, United Nations, May 29, 2019.